- 2 - section 6621(c).1 After agreements of the parties, the question we consider is whether the cost of the work performed on petitioners’ towboat engines constituted a currently deductible expense or whether it is to be capitalized. FINDINGS OF FACT2 A. Background During the taxable years 1992, 1993, and 1994, petitioners were members of an affiliated group of corporations of which Ingram Industries, Inc. (Ingram) was the common parent. Ingram maintained its principal offices in Nashville, Tennessee, on the date the petition was filed in this case. During the years in issue, petitioners were a closely held, diversified group of corporations engaged principally in the wholesale marketing and distribution of microcomputer software and hardware; books and prerecorded video cassettes; inland barge transportation services; energy-related manufacturing, production, and marketing; and insurance. The barge transportation service was conducted by three wholly owned subsidiaries of Ingram--Ingram Barge Co., Inc., Ingram Towing Co., Inc., and Great River Marine Service, Inc. 1 All section references are to the Internal Revenue Code in effect for the years under consideration, and all rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. 2 The parties’ stipulation of facts and the exhibits are incorporated by this reference.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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